“date of distribution”, in relation to any distribution, means-
(a) to the extent that the distribution does not consist of a distribution of an asset in specie–
(i) where the company that makes the distribution is a listed company, the date on which the distribution is paid; or
(ii) where the company that makes the distribution is not a listed company, the earlier of the date on which the distribution is paid or becomes due and payable; or
(b) to the extent that the distribution consists of a distribution of an asset in specie, the earlier of the date on which the distribution is paid or becomes due and payable.